[PART 3] Understanding MIPS 2018: Advancing Care Information

In part three of our four-part series on MIPS 2018, we are going to review the Advancing Care Information category of MIPS. If you missed either of our previous posts, you can find them below. In part one, we reviewed the Quality Payment Program and the general MIPS requirements. This was followed by a close look at the Cost and Quality category requirements last week.

MIPS Advancing Care Information (ACI) Category 2018

This is the second year for the Advancing Care Information category to be counted toward your total MIPS score. As a reminder, the ACI category replaces the old Physician Meaningful Use EHR Incentive program.

The biggest difference between Meaningful Use and the ACI category is that performance does matter. In the past, physicians met the Meaningful Use thresholds and didn’t necessarily worry about the actual performance of the measure. It didn’t matter how low the thresholds were as long as you met them. Now, your performance on ACI measures does matter.

Another change is that ACI attestation or reporting can be done at the group or individual level, not individual attestation only, as was the requirement for Meaningful Use reporting.

As we discussed in part one of this series, your total MIPS score is determined by your performance in four different categories, which are Quality, Cost, Improvement Activities and Advancing Care Information. The ACI category makes up 25% of your final MIPS score.

One other thing to note is that CMS will automatically reweight the ACI category to the Quality category for special status clinicians. This means your Quality category weight would become 75% of your total score and your ACI category would be 0% of your total MIPS score. These special status clinicians include:

Hospital-based Clinicians

Nurse Practitioners

Physician Assistants

Certified Registered Nurse Anesthetists

Clinical Nurse Specialists

Ambulatory Surgical Centers

Non-patient facing (These include groups that have greater than 75% of providers in a TIN that has less than 100 patient facing encounters.)

Advancing Care Information Category Requirements 2018

The ACI reporting requirements are made up of two components, the Base Score and the Performance Score. What you need to remember is that you MUST report ALL BASE measures. If you do not report ALL BASE measures you will receive zero points in the ACI category, and you will not have the ability to report the ACI Performance measures.

If you report all Base measures, you will earn 50 points. From there, you can start racking up more points in this category by reporting on the Performance measures. This category also features bonus points. Your job is to get at least 100 ACI points, so you can get the full 25% ACI score as a part of the MIPS total score.

Base Score + Performance Score + Bonus Score = FINAL SCORE

You could achieve a possible of 165 points, but the score is capped at 100 points. Once you reach the 100-point threshold, you receive full credit in this category. For both the Base and Performance measures you must submit at least 90 days’ worth of data to CMS.

ACI Reporting Methods

Just like last year you have five different reporting methods. They are:

Attestation

CEHRT (through a vendor like Medisolv)

Qualified Registry (through a vendor like Medisolv)

CMS Web Interface* (with help from a vendor like Medisolv)

Qualified Clinical Data Registry (QCDR)

Note: If you are submitting using the CMS Web Interface reporting option you must let CMS know by June 30, 2018.

ACI Base Measures

This year, like last year, you may choose between two ACI Base measure sets. Unlike last year, if you choose to submit the 2015 Certification measures you can earn an additional 10 bonus points for this category.

Here are your options.

ACI 2015 Certification Base Measures

ACI 2014 Certification Base Measures

2015 EHR CertificationMU Stage 3 Functionality

5 Base Measures9 Performance Measures

25 Bonus Points Available

2014 or 2015 EHR CertificationMU Stage 2 Functionality

4 Base Measures7 Performance Measures

15 Bonus Points Available

The column on the left requires you to have more advanced functionality in your EHR representing 2015 EHR certification.

Below we’ve put together a few lists that spell out the 2015 Certification Base measures followed by the 2014 Certification Base measures.

2015 Certification Base Measures

Security Risk Analysis

e-Prescribing

Provide Patient Access*

HIE Send a Summary of Care*

HIE Receive/Retrieve a Summary of Care*

2014 Certification Base Measures

Security Risk Analysis

e-Prescribing

Provide Patient Access*

HIE Send a Summary of Care*

*These noted measures are also included as Performance measures and will allow a clinician to earn a score that contributes to the Performance score category as well.

ACI Performance Measures

The Performance measures are the other half of the ACI category. In the lists below, you’ll see the measures that you can earn points – based on your performance – according to the CMS decile ranking. In other words, how well you perform in comparison with other clinicians.

2015 Certification Performance Measures

Provide Patient Access* (Worth up to 10 points based on performance)

HIE Send Summary of Care* (Worth up to 10 points based on performance)

HIE Receive/Retrieve Summary of Care* (Worth up to 10 points based on performance)

Patient-Specific Education (Worth up to 10 points based on performance)

View, Download or Transmit (VDT) (Worth up to 10 points based on performance)

Secure Messaging (Worth up to 10 points based on performance)

Patient-Generated Health Data (Worth up to 10 points based on performance)

Clinical Information Reconciliation (Worth up to 10 points based on performance)

Available Bonus Measures

You can report to one or more of the following public health and clinical data registries for up to five bonus points.

Immunization Registry (if not already reported)

Public Health Registry Reporting

Clinical Data Registry (CDR) Reporting

Electronic Case Reporting

Syndromic Surveillance Reporting

You can report the 2015 ACI measures using the 2015 CEHRT method for this category and receive 10 bonus points.

You may also select Improvement Activity measures from a select group designated as ACI bonus measures and receive 10 bonus points. (More on this next week.)

ACI Exclusions and Exceptions

Within the Base measures, if you are an Eligible Clinician who transfers a patient to another setting, or refers a patient fewer than 100 times during the performance period, you can still pass the Base measure requirement. For e-Prescribing if you are an Eligible Clinician who writes fewer than 100 permissible prescriptions during the performance period, you can also still pass the Base measure requirement.

CMS has also added some hardship exceptions including insufficient internet connectivity, lack of control over the availability of CEHRT, and extreme and uncontrollable circumstances. You must submit these hardship exceptions unless you are in one of the zip codes that were impacted by one of the major hurricanes or fires last year. If that is the case, you will automatically receive the disaster exception.

Eligible Clinicians may also apply for an exception if their EHR was decertified. CMS hasn’t published a lot of information about these exceptions yet, but you must apply by December 31, 2018.

Tips for the ACI Category

I’ve compiled a list of tips to keep in mind while preparing for the ACI category submission of MIPS.

Report all Base measures to ensure at least 50 points in this category.

Report at least one Public Health measure to get 10 points.

Report a second Public Health measure to get five bonus points.

Select an Improvement Activity measure that will award you the 10-point bonus in this category.

Ensure that your measures in the Performance set are being documented correctly now, since they will be based on performance results.

Everyone must start a 90-day reporting period no later than October 2, 2018.

Performance matters!

Finally, choose a MIPS vendor carefully and understand how they will support you in the calculation of your possible MIPS points in the Advancing Care Information category, as well as helping you to meet all of the MIPS program requirements.

WEBINAR:

LESSONS LEARNED FROM MIPS REPORTING

Wednesday, April 25, 20181 P.M. ET | 12 Noon CT | 10 A.M. PT

In this free educational webinar you will hear about lessons learned from 2017 MIPS reporting

We will provide a sampling of MIPS final scores from hospitals’ submissions to CMS. You’ll learn strategies for creating a yearly comprehensive quality program in your hospital that will prepare you for success year after year.

Join this webinar and learn the tips for preparing your hospital now for the Quality Payment Program.

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Denise Scott

Denise Scott, Director of Ambulatory Services, brings over 30 years in healthcare and over 15 years in HIT implementation, optimization, quality measurement and improvement in the ambulatory physician environment to Medisolv. Prior to joining Medisolv, Denise was a Director of Quality, Informatics and Clinical Integration for two large medical groups in Massachusetts and the former Manager, HIT Services at Masspro where she led a variety of HIT related projects. Denise is a subject matter expert on workflow redesign and Meaningful Use, and is board certified in Nursing Informatics.